E/M Billing: OIG Targets Facilities That Bill E/Ms Which Should Have Been Included in Procedures

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Note:  The following article synopsis was NOT provided by AAPC. It was created by Find-A-Code/innoviHealth.

Article Overview

This article reviews a compliance issue in facility billing where evaluation and management services may be considered part of a procedure rather than separately payable. It discusses an OIG audit, Medicare and CPT-related guidance, and general considerations for procedure-day E/M reporting in hospital settings. The content is intended for coders, billers, compliance staff, and revenue cycle professionals who need to recognize when facility E/M claims may create audit risk.

Why This Topic Matters

Understanding this topic can help facilities reduce avoidable overpayments, audit exposure, and claim denials related to E/M services reported around procedures. It is especially relevant for organizations reviewing documentation, payer policy alignment, and compliance workflows.

Article Sections

  1. OIG audit findings and hospital billing risk

    Summarizes the audit context and the type of hospital claim issues identified. Focuses on the compliance concern and the operational circumstance described in the article.

  2. Check This Tip for Procedure-Day E/M

    Discusses general considerations for reporting evaluation and management services on or near a procedure date. Covers the broader compliance topic and references national coding guidance.

  3. Alternative

    Notes that payer-specific policies may differ for certain E/M services during a procedure global period. Emphasizes the need to verify instructions with the payer and retain supporting documentation.

What You Will Learn

  • How audit findings can highlight facility-level E/M billing risk
  • Why procedure-day E/M reporting can create compliance concerns
  • How national guidance and payer policy awareness affect billing workflows
  • What types of documentation and policy review may be relevant to compliance efforts

Who Should Read This

  • Medical coders
  • Hospital billers
  • Compliance staff
  • Revenue cycle professionals
  • Physician practice managers

Modifiers Discussed

  • CPT: 25
  • CPT: 57

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